Baldivia v. Lota
REITERATIONFacts
1. The Antecedents: Petitioners, former members of the police force of Taal, Batangas, resigned from their positions shortly after the November 1955 elections. They sought to compel the respondent Mayor Flaviano Lota to approve vouchers for their accumulated leave pay at the time of their separation from service. The petitioners alleged their resignations were politically motivated, stemming from their affiliation with a different political faction than the respondent mayor. While some partial payments were made, a balance of unpaid vacation leave remained, which the municipal treasurer prepared vouchers for, but the mayor refused to approve. 2. Procedural History: The petitioners initiated this action by filing a petition for mandamus with the Court of First Instance of Batangas. The lower court, presided over by Judge Conrado M. Vasquez, denied the petition without costs. The petitioners appealed this decision to the Supreme Court, raising only questions of law. 3. The Petition: The petitioners-appellants are before the Supreme Court seeking a reversal of the lower court's decision. They argue that they are legally entitled to their terminal leave pay and that the municipality has the financial capacity to meet these claims. They contend that the respondent mayor's inaction has unjustly deprived them of what is due. The appeal is based on the assertion that the lower court erred in denying their petition for mandamus, despite the mayor's stated justifications of no appropriation and alleged illegality of their appointments.
Issue(s)
Whether the respondent Mayor may be compelled by mandamus to approve vouchers for leave pay in the absence of a specific appropriation ordinance by the municipal council. Whether the petitioners are entitled to their claimed balance of unpaid vacation leave despite the lack of a budget for the same.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, denying the petition for mandamus. The Court held that the respondent mayor was justified in refusing to approve the vouchers for leave pay because there was no appropriation ordinance enacted by the municipal council for the payment of such claims.
Ratio Decidendi
On Issue 1: The Supreme Court held that the respondent Mayor could not be compelled by mandamus to approve the vouchers for leave pay. The Court reiterated the constitutional mandate that no money shall be paid out of the Treasury except in pursuance of an appropriation made by law. Implementing this, Section 2300 of the Revised Administrative Code explicitly states that disbursements of municipal funds shall be made by the municipal treasurer upon properly executed vouchers, pursuant to the budget, and with the approval of the mayor. Since there was no budget or appropriation ordinance setting aside the necessary sums for the petitioners' claims, the mayor was not only justified but bound to refuse the approval of the vouchers. It would be futile and illegal for the mayor to approve a voucher for a claim for which no appropriation has been made by the council. On Issue 2: The petitioners' entitlement to their claimed balance of unpaid vacation leave was rendered moot by the absence of a valid appropriation. While the right to commutation of terminal leave is generally indubitable, its payment is contingent upon the availability of funds duly appropriated by law. The Court noted that the municipal council had not approved any budget for the payment of the claimed leave pay, and the previous payments made to the petitioners were pursuant to a supplementary budget. The respondent mayor's justification that the municipality was heavily indebted and had more pressing obligations was also considered, but the primary reason for denial remained the lack of appropriation. The Court suggested that if the mayor failed or refused to include the claim in the general budget or prepare a special budget, the petitioners could pursue an action against the municipality for recovery and subsequently seek a writ of mandamus against the municipal council and mayor to compel the enactment of the necessary appropriation ordinance.
Main Doctrine
The Supreme Court affirmed the denial of a petition for mandamus to compel the approval of vouchers for leave pay, reiterating the constitutional and statutory requirement that no public funds may be disbursed except pursuant to an appropriation made by law. The Court emphasized that municipal funds require a budget approved by the municipal council, and disbursements must be made pursuant to this budget with the mayor's approval. In the absence of such an appropriation ordinance for the petitioners' claims, the mayor was justified and indeed bound to refuse the approval of the vouchers.